Patsy Curd v. William H. Barksdale
Item
Patsy Curd V. William H. Barksdale. 1849, St. Louis Circuit Court Historical Records Project, accessed October 9, 2026, https://digitalexhibits.library.washu.edu/s/ccr/item/60979
- Case Title
- Patsy Curd v. William H. Barksdale
- Series
- Freedom Suits
- Plaintiff
- Curd, Patsy
- Defendant
- Barksdale, William H.
- Date Filed
- 1849-11-06
- Next Friend
- Meachum, John Berry
- Filing Date
- 1849-11-06
- Plaintiff’s Attorney
- Garesche, Alexander J. P.
- Defendant’s Attorney
- Wells, Joseph
- Buckner, Aylett H.
- Court Name
- St. Louis Circuit Court|St. Louis County Court
- Court Term
- 1850-04
- Judge
- Horeseltero, A.
- Hamilton, Alexander
- Clerk
- Cerre, Michael S.
- Tiffett, P.
- Fallation, Angus L.
- Justice of the Peace
- Colin, John W.
- McLain, James S.
- Sheriff
- Labe., Louis J.
- Sal., Louis S.
- Belt, Henry B.
- Shands, E.M.
- George
- Sworn Declarant
- Dyer, T.B.
- Creighton, William
- Scott, Thomas
- Jury Foreman
- Moose, H.M.
- Cause of Action
- Petition for Freedom
- Case Notes
- Plaintiff claimed to have moved from Virginia to Chillicothe, Ohio, as slave of Dr. Isaac Curd; lived there over 5 years; she was bound to Dr Curd until age of 21; defendant bought plaintiff & 3 children; includes depositions and bill of sale for $1,100.
- Disposition
- Verdict for Plaintiff
- Case Number
- 1
- Identifier
- ccr1850.27424.032
- Source
- Missouri State Archives - St. Louis
- Rights
- Public Domain
- PDF Download
- Download PDF of all images
- Transcription
-
**Patsy Curd vs. William H. Barksdale**
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**Page 1** (27424_001.jpg)
> *Legal Function: Verdict*
[illegible] 1850 [illegible] [illegible] [illegible] pled 20 May 1850 overruled 20p 258
Trial 20. p. 342 verdict. for plff. March 6th 1851. 20 p. 343.
> *Legal Function: Caption*
No 1. Saint Louis Circuit Court
April Term 1850
Patsy Curd
vs
summons
William H Barksdale
Pet for freedom
*[illegible] [illegible]
issued Nov 6th 1849 M S.Cerre Clk*
> *Legal Function: Order*
St Louis Mo 5 Nov 1849
[illegible] that Patsy
Curd the within [illegible] petitioner [illegible] [illegible]
to sue as a poor person for the freedom of herself
& her two children therein named that she shall
have reasonable liberty to attend her counsel
& the court as [illegible] may require that neither
she nor her [illegible] children hereinnamed be [illegible]
[illegible] of the jurisdiction of the Court
and that they be not subject to any sever
ity on account of her and their applic
ation[?] for freedom
attest M S.Carre Clk
*A Horeseltero[?] Judge 8
Judicial Curcuit[?] [illegible] [illegible] $ 2 [illegible] 1 $ 3 due*
> *Legal Function: Certificate of Execution*
Executed this wit in the County of St Louis on
the 6th day of November 1849 1st by reading the order to
William H Barksdale the "within named dependant
[illegible] Executed by delivering a certified copy of the petition
an a true copy of the summons to William H
Barksdale the said depend
*Louis J Labe. Shff
By [illegible] [illegible] [illegible] fee $ [illegible]
$ 2.00*
---
**Page 2** (27424_002.jpg)
> *Legal Function: Summons*
County of St. Louis , Ss.
The State Of Missouri , To the sheriff of St Louis County. Greeting:
We command you To Summon William H .
Barksdale [illegible] that he be and
appear
before the Judge of our Circuit Court , on the first day of the
next term therof, to be held in the City of St. Louis ,
within and for the County of St. Louis , on the third Mon
day of April[?] next, then and there to answer unto
Patsy Curd of her Petition for free
dom here to [illegible]
And have you then there this Writ.
*Witness. Micheal S. Cerre, Clerk of said
Court with the seal thereof hereto affixed, at
office in the city of St. Louis , this
6th day of Novr in the
year of our Lord eighteen hundred and forty
nine M.S.Cerre Clerk I acknowledge myself bound for all costs that may accure in the above cause. Witness my hand an seal at St. Louis , this day of
18*
---
**Page 3** (27424_003.jpg)
> *Legal Function: Certificate of Filing*
Patsey Curd
vs
Defts answer
Wm H Barksdale
[illegible]
*Filed April 22d 1850 M. S. Cere clk*
---
**Page 4** (27424_004.jpg)
---
**Page 5** (27424_005.jpg)
> *Legal Function: Certificate of Filing*
Patsy Curd
vs
Wm H . Barksdale
Petition for freedom
Filed Nov 6th 1849
M S Cerre Clk
---
**Page 6** (27424_006.jpg)
> *Legal Function: Petition*
Patsy Curd Plaintiff
vs William H Barksdale defendant
In the circuit
[illegible] Court of
[illegible] nov Term 1849
St Louis County
Plaintiff states that she is now held in bondage [illegible] as
his absoulte slave, by defendant and that she is entitled
to her freedom [illegible]
And plaintiff further declares that inasmuch as she was
free, being [illegible] I illegally held in slavery at the
time that her two childern Robert aged about six years
and Yamima[?] aged about ten years were born, they are
also free
[illegible] plaintiff further declares that
for five years she lived in the state of Ohio with the per
mission & in the capacity of house servant for her then
master Dr Isaac Curd
That this occured about eighteen years ago
that then [illegible] that she was entitled to her freedom she was
prevented from [illegible] it, by the fact (as she is informed
& believes) she was bound in apprenticeship agreably
to the laws of Ohio to serve the said Dr Curd until she
should have attained the age of twenty one years
that she has long since attined this age but she and her
childern are still in servitude she therefore prays
that judgment be rendered in her favor that she
&her two childern Robert &[?] Yemima[?] be declared free
*[illegible] [illegible] A B Paresche[?] [illegible]*
> *Legal Function: Notarization*
John Berry Meachum[?] being duly sworn on his oath
says that he believes the above petition matters therein
as stated to be true
*John B Meachum[?] Sworn to & Subscribed
before me this 5th november
1849 P. Tiffett[?] Clk*
---
**Page 7** (27424_007.jpg)
> *Legal Function: Order*
St Louis Mo 5th Nov 1849
Ordered that Patsy Curd the
within named petitioner have leave to sue as a poor person for the freedom
of herself & her two children therein named, that she shall
have reasonable liberty to attend her counsel & the court
as reason may require; that neither she nor her two
children herein named he [illegible] removed out of the Juris-
diction of the Court and that they be not subject to any
servity on account of her and their application for
freedom
*A Hamelton,
Judge 8th Judicial
Circuit Mo.*
> *Legal Function: Certificate of Filing*
Petition of Patsy Curd
in behalf of herself & her two
children [illegible] to sue for
her & their freedom
*Filed Nov 6th 1849 M.J.Cerre Clk*
> *Legal Function: Order*
St Louis Missouri , Nov, 6th 1849[?] ordered that Pastey Curd the within petitioner
have leave to sue as a poor person for the freedom of herself & her two children therein named,
that she shall have reasonable liberty to attend her counsel & the court as occasion may
require; that neither she nor her two children herein named be removed out of the jurisdiction
of the court and that they be not subject to any severity on account of her and their ap
plication for freedom
---
**Page 8** (27424_008.jpg)
> *Legal Function: Complaint*
To the Honorable the Judge of the St St. Louis Circuit Court
Your petitioner Patsy Curd respectfully represents
that she &[?] her two children Robert aged about six years and
[illegible]eminia about ten years old are now held in slavery and
are the slaves of one [illegible] William H Barksdale and prays
permission for leave to sue as a poor person for her [illegible] in order to establish her and their right to freedom
and assigns the following reasons
That for five years her master (then Dr Isaac Curd ) required
her to live with him in the State of Ohio ,
that her desires to leave him, [illegible] as your petitioner was
then informed & believes, caused her to be bound to him
[illegible] which your petitioner as she was informed & believes
was impelled to serve him until she arrived at
the age of twenty one years
That she has fully completed this term being now over
twenty one years of age and that she is a poor person owning no property of any kind whatever
wherefore and that by reason simply of her residence in
that State of Ohio by her master's direction, she is the [illegible]
of Ohio give her her feedom she asks persmission
as above [illegible] [illegible] that she being free
the said Barksdale has no right to detain her children in
freedom= All of which is respectfully submitted
Witness
*J.B. Meachum[?] her
Patsy X Curd
mark*
> *Legal Function: Notarization*
John Berry Meachum[?] being duly sworn on his oath says
that [illegible] the above petition & the matters as therein stated
he believes to be true
*J.B.Meachum[?] Sworn to and subscribed before me,
the 5 day of November, A.D. 1849 John W .Colin,
Justice of the Peace*
---
**Page 9** (27424_009.jpg)
> *Legal Function: Bill of Sale*
Bill Sale
from
T B Dyer
for
Negro woman Patsy
---
**Page 10** (27424_010.jpg)
Know all men by these present, that Thomas B
Dyer of the County and City of St Louis have this day
for and in consideration of the Sum of Eleven
hundred dollars to me in hand paid sold to
William H Barksdale four negro slaves namely a woman
called Patsy believed to be thirty years old and
her three children the oldest being named Nelly
the next Jamima[?] and the youngest Robert all
of which I warrant to be sound in body and
mind and I hereby warrant them to be slaves
for life and guarantee the title to same against
all other claims or claimants what so ever in
testimony where of I have hereunto set my
hand and affixed my seal this 7th day
of September 1847
*T B Dyer*
---
**Page 11** (27424_011.jpg)
> *Legal Function: Defendant's Answer*
In the St Louis Circuit
Court Spring Term
1850
Patsy Curd Plaintiff
vs
William H Barksdale Defendant
Defendant for answer to plaintiffs Petition
says that he admits that he does now and has
[illegible] the month of September 1847 held said
plaintiff in bondage as a slave, that he Defend
ant an the 7th day of September 1847 He purchased
said plaintiff from Thomas B Dyer also three of
her children. One of whom has since died, the
other two are the ones named in said plaintiffs
Petition, Defendant says he was informed &
believes that said Plaintiff and her said children
were braught to St Louis to be sold by, John
Curd now of St Josephes Missouri and by him left
with said Thomas B Dyer who was a friend
relative of said Curd to be sold that he defendant
took said negroes on trial & after having kept them
a few weeks became satisfied to buy them and
did buy them from said Dyer & took his will
of sale for them which is hereto anexed & paid
him the said Dyer for said negroes Eleven hundred
dollars the sum mentioned in said bill of sale
Defend and says he has since said purchase keept
and used said negroes as his slaves
Defendant says he knows nothing of the truth
of the statements of said plaintiff that she
resided five years in Ohio or that she is Entitled
to her freedom & that he knows nothing of her
history previous to the time he Comenced his
negotiations [illegible] buy her and her children
Defendant says he is advised that all coloured
---
**Page 12** (27424_012.jpg)
persons in the state of Missouri are taken in
law prima facie[?] to be slaves. He says that said
plaintiff & her children are coloured persons that
they were represented to him by said Thos B Dyer
to be slaves, and that he Defendant baught them
believing them to be slaves. He says that the
character of said Dyer & of said Curd who he
defendant understood had brought said plaintiff &
children to St Louis was such that Defendant
did not think it necessary, nor did he investigate
their title to said negroes but took them as
slaves relying on his bill of sale. Defendant
says he never heard from said plaintiff nor
from any lawer to which he attached the
slightest credit that said plaintiff or her
children were free, til he was served with
process in this cause. Defendant does not
admit any of the statements in said petition
Except that he holds said plaintiff & her children
in slavery. He knows of no fact [illegible] to
Establish the Claim of said plaintiff or
Either of her Children to freedom & He asks
the Court to hold said parties to street legal
proof of Every fact necessary to Establish her
or their freedom
*W.H. Barksdale Subscribed and sworn to before
me this 1st. day of April AD 1850 M S . Cerre Clk*
---
**Page 13** (27424_013.jpg)
> *Legal Function: Notice to Take Deposition*
Patsy Curd plft[?]
vs
Wm. H. Barksdale deft
Notice of depositions for pltff
> *Legal Function: Certificate of Service*
served this notice in the County of St Louis on this
9th day of March 1850 By delivering a true
copy thereof to Wm H Barksdale the within
named defendant
*Fee 50 c Louis S Sal.
Shff
By EM Shands
Dpty*
---
**Page 14** (27424_014.jpg)
> *Legal Function: Notice*
Patsy Curd of color plaintiff
vs
William H. Barksdale
In the St St. Louis Circuit Court
of St Louis County State of Missouri . To William H. Barksdale Esq of above named plantiff
You are hereby notified that depositions of witnesses, to be read in evidence in the above
entitled cause, on the part of the plaintiff will be taken at the
[illegible] office of [illegible] is Guighton [illegible] green Attornies & Councellers
at Law in Chillicothe
in the County of Ross and State of Ohio on
the eleventh day of May AD 1850 between the hours of
eight o'clock, in the forenoon, and six o'clock, in the afternoon, and that the taking of said
deposition, if not completed on that day, will be continued, from day to day, at the same place, and
between the same hours, till completed.
*A [illegible] B Paresche[?]
pltff's[?] Atties[?]*
---
**Page 15** (27424_015.jpg)
> *Legal Function: Writ*
County of St. Louis , s s.
The State Of Missouri , To any Judge, Justice of the Peace, or other Judicial Officer of the State of
Greeting:
Know Ye, that we, in confidence of your prudence and fidelity, do, by these presents, authorize
you to cause to come before you, to be examined as witnesses in a cause depending in our
Circuit Court for the County of St. Louis , in the State of Missouri , wherein Patsy Curd
of color is
plaintiff, and William H. Barksdale is
defendant, all
and every such person, and at such time and place, as shall be named to you for that purpose by the
said Patsy Curd her
Attorney or Agent. And we command you to examine all and every such person upon his oath or
solemn affirmation first made or taken before you, to testify the whole truth touching his knowledge of
any thing relating to the said matter in controversy between the said parties; and that you do take
such his examination, and reduce the same into writing. When you shall have so taken his examination,
you are to cause the witness to sign the same, and to that and each examination, at the foot thereof, you
are to append your certificate, setting forth the facts that the examination was subscribed and sworn to
or affirmed by the witness, and the day, as well as between what hours of the day, on which it was
done, as also the place of residence of the witness, if known to you. Should any paper or exhibit be
produced or proven, or referred to by the witness, you are to describe the same in his examination, or
cause it to be so marked by him, as to establish its identity, and attach the same to his examination.
The examinations thus taken you will cause to to be accompanied by a certificate of your official
character, attested by the seal of State; or, should it be more convenient, such authentication and proof
of your official character may be made by the certificate and seal of the clerk of any court of record
of any county of the State, District or Territory in which you reside, stating also, in addition to the
facts of his being clerk and that the court is one of record, that, at the time when the depositions were
taken, you were an acting judge, (or other such officer to whom this commission is addressed,) and
duly commissioned as such. And you will return the same and all exhibits produced to you, annexed
hereto, carefully closed up and under your seal, directed to the Clerk of the Circuit Court in and for
the county of St. Louis , Missouri , with the names of the said parties litigant endorsed thereon, with all
convenient speed.
*Witness, Michael S Cerre , Clerk of our said Circuit Court ,
at the city of St. Louis , this day of
in the year of our Lord one thousand
eight hundred and forty- M S . Cerre Clerk, C. C.*
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**Page 16** (27424_016.jpg)
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**Page 17** (27424_017.jpg)
> *Legal Function: Deposition*
Deposition of Witnesses taken in a cause pending in
the Circuit Court of the County of St Louis state of Missouri
wherein Patrey Curd, of color, is Plaintiff and William H Barksdale is defendant in presence of the notice and
Commission hereto attached, and at the time and place
in said notice mentioned
William Creighton, of the city of Chillicothe, of lawful age
being first duly sworn by me, as hereafter certified
deposes as follows
Question - Was you acquainted with Doctor Isaac
Curd formerly of Goochland County Virginia, now
residing in the state of Missouri
Answer - I was I knew him first in the
year 1825, when he removed, with his family to
Chillicothe in the state of Ohio , where with his
family [illegible] continued to reside for several years
and practiced his profession — duing his residence
in Ohio he and his family were my near neighbors
Question - Do you know whither Doctor Curd brought
with him to Ohio a colored girl named Patsy
and whether he took said girl with him, an his
removal to Missouri
Answer - I know that he broughts with him a
small colored girl named Patsy who resided
in his family during the time he livedin Ohio
and that he took her with him when he
removed to Missouri
Question - How many years did doctor Curd reside
with his family in Ohio
Answer - I cannot state positively, but to the
best of my recollection and belief he resided in Ohio
between five and six years - a part of the time in
Chillicothe and a portion of the time on my
---
**Page 18** (27424_018.jpg)
farm five miles from town where he continued
to reside for about two years, within a few years
of my own residence- He was my near neighbour
whelst I lived in town and in the county during
all of his residence in Ohio I was very intimate
with him and his family and faith saith not
*W. Creighton*
> *Legal Function: Deposition, part 2*
Also Thomas Scott of the city of Chillicothe
aforesaid, of lawful age being first duly sworn by me
as hereafter certified deposes as follows
Question by Plaintiff attorney -
Was you acquainted with Doctor Issac Curd
referred to in the forgoing deposition and if yea when
and where
Answer - I became acquainted with the Doctor
and his family shortly after they removed from Virginia
to this city ( Chillicothe )
Question by same - Do you know whether the Doctor
broughts with him from Virginia a colored girl
named Patsy , and if so did said girl reside with
him during his residence in Ohio , and did he take her
with [illegible] him when he removed to Missouri
Answer - The Doctor broughts with him from Virginia
in to Chillicothe a colored girl named Patsy , who
continued to reside with him during his residence in
Chilliwith - The Doctor resided for a time in the county
near Chillicothe - [illegible]
did he practice at his profession in your family
Answer He did
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**Page 19** (27424_019.jpg)
Question by same
State Whether Doctor Curd a [illegible] [illegible], during his
residence in Chillicothe applied to you to draw
an indention binding Patsy until she was of age
Answer- [illegible]
*Thomas Scott*
> *Legal Function: Notarization*
I James S Mclain[?] a Justice of the peace in and for
the Township of [illegible], in the county of Ross, Ohio, do
hereby certify, that the above named William Creighton
and Thomas Scott , were by me first duly sworn to
testify the truth, the which hath and nothing but the
truth, and that the foregoing depositions by them
instruction [illegible] were [illegible] to writing by [illegible]
and were taken at the time and place spcified in the
endorsd[?] notice-
In testimony whereof I have
hereunto set my hand officially this 11th day of May in
the year 1850
*Janes S M clain[?] J.P. Fee security deposition 86 [illegible] 2 [illegible] 08 94 [illegible] seal 50 1.44paid by Plff atty*
---
**Page 20** (27424_020.jpg)
> *Legal Function: Notarization, part 2*
The State of Ohio
Ross County Ss
I Angus S.Fullerton Clerk of the Court
of Common Pleas for the County aforesaid
do certify that James S.Mc[?]Lain Esquire
before whom the aforegoing deposition was
taken, was at the time of taking the same
and now is an acting Justice of the peace in & for the county
aforesaid duly commissioned & sworn as such
In testimony whereof I have hereunto set my hand & seal of
office this 13th day of May A.D. 1850.
*Angus L Fallation Clerk*
> *Legal Function: Certificate of Filing*
Opened & filed 21st
May 1850
M S Cerre Clk
Patsy Curd of color
vs
Wm H Barksdale
Defens.[?] of plaintiff
20 Cts postage [illegible] by Garesche[?]
> *Legal Function: Deposition, part 3*
[illegible]
---
**Page 21** (27424_021.jpg)
> *Legal Function: Motion to Supress Deposition*
Patsy Curd
vs
Wm H Barksdale
Motion to suppress
Depositions
*Filed Nov 18th 1850 M.S .Cerre clk*
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**Page 22** (27424_022.jpg)
> *Legal Function: Motion to Supress Deposition, part 2*
Patsy Curd Plaintiff
vs
William H Barksdale Defendant
In the Circuit Court
of St Louis County
November Term 1850
The defendant by his attorney causes &
moves the court to supress[?] the depositions filed
by the plaintiff in this cause for the following
reasons [illegible]
1st The commission under which said depositions were
taken was not & is not directed to any judge
justice of the peace or other Judicial officer of the
government in which the deponents resided nor to
the officers of any government
2nd There is no evidence in said depositions that the
witness were sworn to testify the whole truth as
required by the law of missouri
3d there is no evidence accompanying said depositions
that the examation of deponents was reduced
to writing in the presence of the officer who
took and certified the depositions
4 there is no evidence that the depositions were
subscribed & sworn to as required in sec 16 of the
law of missouri [illegible] depositions
5th Said depositions are in other respects irregular
informal & illigal
*Wells & Buckner
attys for Defendant*
---
**Page 23** (27424_023.jpg)
> *Legal Function: Subpoena*
4th
Patsy Curd
vs
Wm H. Barksdale
subpoena
*Wm H. Barksdale
and Thomas Dyer.*
> *Legal Function: Certificate of Execution*
Executed March
30 1851
*Henry Belt Sheriff
By George [illegible]
Depty [illegible] $ 1,00*
---
**Page 24** (27424_024.jpg)
> *Legal Function: Subpoena*
County of St. Louis , ss.
The State of Missouri , To Thomas Dyer
and William H. Barksdale (firm of Craw McCrury & Co.)
Greeting:
You are hereby commanded, that setting aside all manner of excuse and delay, you appear be-
fore our Circuit Court , for the county aforesaid, on the fourth day of March
at the City of St. Louis , then and there to
testify, and the truth to say in a certain matter of controversy now pending in our said Court,
wherein Patsy Curd (of Color) is
plaintiff and William H. Barksdale is
defendant on the part of the plaintiff
and herein you are in nowise to fail.
*Witness, Wilson Primm,[?] M. S. Cerre Clerk of our said Court,
with the seal thereof hereto affixed, at office, in
the City of St. Louis , this twenty Eighth
day of February in the year of our Lord
one thousand eight hundred and fourty[?] fifty one M. S. Cerre Clerk, C. C.*
---
**Page 25** (27424_025.jpg)
> *Legal Function: Caption*
4[?]
Patsy Curd
vs
Backsdale
*subp.[?]. L. M. Kennett*
> *Legal Function: Certificate of Execution*
Executed March 3d
1851
*[illegible]
Sheriff
[illegible]
Depty [illegible] $,8. 50 cts*
---
**Page 26** (27424_026.jpg)
> *Legal Function: Subpoena*
County of St. Louis , ss.
The State of Missouri , To Luther M. Kennett
Greeting:
You are hereby commanded, that setting aside all manner of excuse and delay, you appear before
our Circuit Court for the county aforesaid, on the fourth day of March
at the City of St. Louis , then and there to
testify, and the truth to say in a certain matter of controversy now pending in our said Court,
wherein Patsy Curd (of Color) is
plaintiff and William H. Barksdale is
defendant on the part of the plaintiff
and herein you are in no wise to fail.
*Witness, Wilson Primm,[?] M. S. Cerre
Clerk of our said Court,
with the seal thereof hereto affixed, at office, in the
City of St. Louis , this first day of
March in the year of our Lord one thousand
eight hundred and forty fifty one M. S. Cerre Clerk, C. C.*
---
**Page 27** (27424_027.jpg)
> *Legal Function: Jury Instructions*
If the Jury believe from the evidence that the
plaintiff Patsy was the slave of Dr Isaac Curd
that her master the said Dr Isaac Curd remo-
ved her to the state of Ohio & there resided
&[?] that the said Patsy resided with him they
will find for the plaintiff=
That if the Jury believe from the evidence
&[?] from the instructions given by the
Court that the said Patsy is free they
will also find that her children from [illegible] [illegible] to her residence in [illegible] are free=
That if the Jury believe that in the bill of
sale executed by Dyer to the defendant [illegible]
filed as part of the defendant's answer
is [illegible] that [illegible]then[illegible] Robert Nelly [illegible] are [illegible]
as the children of the said Patsy = that their the
and as [illegible] [illegible] [illegible]
---
**Page 28** (27424_028.jpg)
in the of sale evidence first that of children of the saw Patsy = of
---
**Page 29** (27424_029.jpg)
Agreed to
If the plaintiff has not [illegible] by evidence
satisfactoy to the jury that the plaintiff
did reside in the state of Ohio or [illegible] in [illegible] they will
find for the Defendant
Agreed to
All coloured persons in Missouri are
presumed in law to be slaves & unless
the plaintiff in this suit has proven
to the satisfaction of the jury that she
is a free woman they will find
for the defendant
Agreed to
In this suit it [illegible] on the
plaintiff to establish her freedom
by competent proof, & if she has
not done so the jury must find
for the Defendant
---
**Page 30** (27424_030.jpg)
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**Page 31** (27424_031.jpg)
> *Legal Function: Jury Verdict*
Patsy Curd
vs
Wm H Barksdale
We the gentleman of the Jury
find for the plaintiff in this case
*H.M.Moose [illegible]*
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Patsy Curd V. William H. Barksdale. 1849, St. Louis Circuit Court Historical Records Project, accessed October 9, 2026, https://digitalexhibits.library.washu.edu/s/ccr/item/60979